Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The HC modified the prior order, directing that the reference to Rs.50 lakhs be read as Rs.1.73 crores. The original Petitioners are granted six weeks to furnish an additional bank guarantee of Rs.1.23 crores or a consolidated bank guarantee of Rs.1.73 crores; upon provision of a consolidated guarantee, the customs authorities may return the original Rs.50 lakhs guarantee to the original Petitioners. Non-compliance permits the customs authorities to pursue any lawful measures, including seeking relief from the HC. The interim application is disposed of on these terms without costs, and all concerned must act on an authenticated copy of the order.
The HC modified the prior order, directing that the reference to Rs.50 lakhs be read as Rs.1.73 crores. The original Petitioners are granted six weeks to furnish an additional bank guarantee of Rs.1.23 crores or a consolidated bank guarantee of Rs.1.73 crores; upon provision of a consolidated guarantee, the customs authorities may return the original Rs.50 lakhs guarantee to the original Petitioners. Non-compliance permits the customs authorities to pursue any lawful measures, including seeking relief from the HC. The interim application is disposed of on these terms without costs, and all concerned must act on an authenticated copy of the order.
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